{"operation":"document","citation":"CPF 52024017WL","title":"ALYESKA PIPELINE SERVICE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-03-13","effective_on":null,"summary":"CLOSED warning letter citing 195.205(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52024017wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52024017wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52024017wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52024017WL","body":"Warning Letter involving ALYESKA PIPELINE SERVICE CO. PHMSA's enforcement data identifies the cited regulation as 195.205(b)(1). The case was opened on 2024-03-13 and is reported as closed as of 2024-03-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52024017WL_Operator Response to Notice_05202024_(23-277227).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52024017WL/52024017WL_Operator%20Response%20to%20Notice_05202024_(23-277227).pdf\n\n52024017WL_Warning Letter_03132024_(23-277227).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52024017WL/52024017WL_Warning%20Letter_03132024_(23-277227).pdf\n\n52024017WL_Warning Letter_03132024_(23-277227)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52024017WL/52024017WL_Warning%20Letter_03132024_(23-277227)_text.pdf\n\n52024017WL_Warning Letter_03132024_(23-277227)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: John.kurz@alyeska-pipeline.com\nMarch 13, 2024\nMr. John Kurz\nPresident and CEO\nAlyeska Pipeline Service Company\nPOB 196660 MS 502\nAnchorage, AK, 99519\nCPF 5-2024-017-WL\nDear Mr. Kurz:\nFrom June 7 to December 15, 2023, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected your Trans-Alaska Pipeline System Pump Station 5, Tank 150 inspection and repair\ndocumentation in Anchorage, Alaska.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 195.205 Repair, alteration and reconstruction of aboveground breakout tanks\nthat have been in service.\n(a)…\n(b) After October 2, 2000, compliance with paragraph (a) of this section requires the\nfollowing:\n(1) For tanks designed for approximate atmospheric pressure, constructed of\ncarbon and low alloy steel, welded or riveted, and non-refrigerated; and for tanks\n\n\n\nbuilt to API Std 650 (incorporated by reference, see §195.3) or its predecessor\nStandard 12C; repair, alteration; and reconstruction must be in accordance with\nAPI Std 653 (except section 6.4.3) (incorporated by reference, see §195.3).\nAlyeska failed to repair Tank 150 in accordance with the requirements of API 653 section\n9.10.1.2, as required. During welding of multiple patch plates to the floor of Tank 150, the\ncontractor failed to follow the root weld examination requirements of API Std 653 section\n9.10.1.2(c).\nAPI Std 653 section 9.10.1.2(c) requires that “Perimeter welds on welded-on patch plates within\nthe critical zone shall be two-pass, minimum, and examined per 12.1.1.3 and 12.1.7.2.” API Std\n653 section 12.1.7.2 requires that “In addition to the requirements of 12.1.7.1, the root and final\npass of a welded-on patch plate weld in the critical zone…shall be visually examined and\nexamined by either magnetic particle or liquid penetrant method over its full length.” However,\nthe following patch plates did not have the required root weld examination completed: R06, R07,\nR10, R11, R12 and R13.\nThe patch plates were installed in Tank 150 in the July-August 2023 timeframe. A review of\nAlyeska’s records included a letter from Aiken Engineering Company1 to TEAM Industrial\nServices dated August 25, 2023 stating:\n“During the repair of Alyeska Pipeline Tank 35-TK-150, the magnetic particle (MT)\ninspection of the root weld in the critical zone was not performed while placing several of\nthe annular patch plates. Thus, the patch plates were placed and welded without root pass\nMT.”\nTherefore, Alyeska failed to repair Tank 150 in accordance with § 195.205(b)(1) as required.\n2. § 195.205 Repair, alteration and reconstruction of aboveground breakout tanks that\nhave been in service.\n(a)…\n(b) After October 2, 2000, compliance with paragraph (a) of this section requires the\nfollowing:\n(1) For tanks designed for approximate atmospheric pressure, constructed of\ncarbon and low alloy steel, welded or riveted, and non- refrigerated; and for tanks\nbuilt to API Std 650 (incorporated by reference, see §195.3) or its predecessor\nStandard 12C; repair, alteration; and reconstruction must be in accordance with\nAPI Std 653 (except section 6.4.3) (incorporated by reference, see §195.3)\nAlyeska failed to repair Tank 150 in accordance to the requirements of API Std 653 as required.\nThe contractor failed to perform magnetic particle or liquid penetrant non-destructive\nexamination of the shell-to-bottom joints prior to installing patch plates, as required by API Std\n653 section 12.1.6.3.\n1 See Submittal F12153-23002 WO 211002340 35-TK-150\n\n\n\nAPI Std 653 section 12.1.6.3 requires that “The existing weld at the shell-to-bottom joint shall be\nexamined by visual as well as by magnetic particle or liquid penetrant methods, for full length\nunder a weld-on patch plate. An additional 6 in. of the shell-to-bottom joint on each side of the\nwelded-on patch shall be examined similarly before placement of the repair plate to assure weld\nintegrity and confirm the absence of weld cracks.”\nThe patch plates were installed in Tank 150 in the July-August 2023 timeframe. A review of\nAlyeska’s records included a letter from Aiken Engineering Company2 to TEAM Industrial\nServices, dated August 25, 2023 stating:\n“Also, the MT examination of the shell-to-bottom joint for the full length of the patch\nplate plus 6 inches to either side was not completed prior to placing the patch plate. There\nare 15 patch plates in this condition. They are identified as R06, R07, R10, R11, R12,\nR13, R22, R27, R39, R40, R41, R42, R43, R44, and R48. After the repair was completed,\nall the remainder of the shell-to-bottom joint was MT examined which exceeds the API\nspecification.”\nTherefore, Alyeska failed to repair Tank 150 as required pursuant to § 195.205(b)(1).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a\nrelated series of violations. For violation occurring on or after January 6, 2023 and before\nDecember 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the\nviolation persists, up to a maximum of $2,576,627 for a related series of violations. For violation\noccurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not\nexceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for\na related series of violations. For violation occurring on or after May 3, 2021 and before March\n21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation\npersists, up to a maximum of $2,251,334 for a related series of violations. For violation\noccurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not\nexceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for\na related series of violations. For violation occurring on or after July 31, 2019 and before January\n11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation\npersists, up to a maximum of $2,186,465 for a related series of violations. For violation\noccurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may\nnot exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in\nAlyeska Pipeline Service Company being subject to additional enforcement action.\n2 See Submittal F12153-23002 WO 211002340 35-TK-150\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2024-017-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 C. Lyon (#23-277227)\nAllison Iversen, Director HSEC, Allison.Iversen@alyeska-pipeline.com","truncated":false,"body_characters":8827}